Which cases are most cited on Section 2(19)?

CIT v. Multiplan India Ltd. (38 ITD 320) — 2,267 citing judgments; GKN Driveshafts (India) Ltd. v. ITO (259 ITR 19) — 1,349 citing judgments; Pr. CIT v. Totagars (395 ITR 611) — 1,074 citing judgments; Mavilayi Service Co-operative Bank Ltd. v. CIT (431 ITR 1) — 999 citing judgments; State Bank Of India v. CIT (389 ITR 578) — 817 citing judgments.

How many judgments discuss Section 2(19)?

BharatTax indexes 744 ITAT, High Court and Supreme Court judgments that discuss Section 2(19) (Section 2(19)).

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“Section 2(19)”

Q: What is the leading case on Section 2(19)?

CIT v. Multiplan India Ltd. (38 ITD 320) is the decision most relied on for Section 2(19), cited in 2,267 judgments on BharatTax. An appeal before the Income Tax Appellate Tribunal can be dismissed for non-prosecution or treated as unadmitted when the appellant fails to appear, cooperate, or show diligence, in accordance with Rule 19(2) of the Income-tax (Appellate Tribunal) Rules. The law aids the vigilant, not those who sleep on their rights.

Section References (mined)Section 2Section 2(19)744 judgments

The decision most relied on for Section 2(19) is CIT v. Multiplan India Ltd. (38 ITD 320), cited in 2,267 judgments on BharatTax.

Leading authorities on Section 2(19)

CIT v. Multiplan India Ltd.

38 ITD 320 · 1991 · ITAT

2,267

citing judgments

An appeal before the Income Tax Appellate Tribunal can be dismissed for non-prosecution or treated as unadmitted when the appellant fails to appear, cooperate, or show diligence, in accordance with Rule 19(2) of the Income-tax (Appellate Tribunal) Rules. The law aids the vigilant, not those who sleep on their rights.

GKN Driveshafts (India) Ltd. v. ITO

259 ITR 19 · 2003 · Supreme Court

1,349

citing judgments

When a notice under Section 148 of the Income Tax Act is issued, the Assessing Officer is bound to furnish reasons for reopening upon the assessee's request and must dispose of the assessee's objections to the notice by passing a speaking order.

Pr. CIT v. Totagars

395 ITR 611 · 2017 · High Court

1,074

citing judgments

Interest income earned by a cooperative society from surplus deposits or investments held with a cooperative bank is not eligible for deduction under Section 80P(2)(d) of the Act.

Mavilayi Service Co-operative Bank Ltd. v. CIT

431 ITR 1 · 2021 · Supreme Court

999

citing judgments

Section 80P(4) serves as a proviso to Section 80P(1) and (2), excluding only cooperative banks that are cooperative societies and possess an RBI license for banking business. Its purpose is to exclude cooperative banks operating like commercial banks that lend money to the public.

State Bank Of India v. CIT

389 ITR 578 · 2016 · High Court

817

citing judgments

Income arising from a cooperative society's surplus funds invested in short-term deposits and securities is not attributable to the society's core activities and, therefore, is not eligible for exemption under Section 80P(2)(a)(i) of the Income-tax Act.

Pr. Commissioner of Income Tax and Anr. v. Totagars Cooperative Sale Society

392 ITR 74 · 2017 · High Court

762

citing judgments

Interest income earned by a cooperative society from its investments or surplus deposits with a cooperative bank is eligible for deduction under Section 80P(2)(d) of the Income-tax Act, 1961.

Subramanian and Anr. v. Siemens India Ltd. and Anr.

156 ITR 11 · 1985 · High Court

541

citing judgments

When there is a conflict between the decisions of non-jurisdictional High Courts, the view that favors the assessee should be preferred.

Citizen Co-operative Society Ltd. v. ACIT

397 ITR 1 · 2017 · Supreme Court

499

citing judgments

A co-operative credit society engaged in banking business with the general public, accepting deposits from non-members and advancing loans to non-members, is treated as a co-operative bank. Such a society falls under the exclusionary clause of Section 80P(4) and is not eligible for deduction under Section 80P(2)(a)(i).

Judgments citing Section 2(19)

Shri Basaveshwar Souharda Sahakari Sangha Niyamit, Kalloli vs. Income Tax Officer, Ward - 1, Gokak

In the result, the appeal filed by the appeal is allowed”

ITA 485/PAN/2025[2022-23]Status: DisposedITAT Panaji17 Mar 2026AY 2022-23

Section 80P(2)(a)Section 80P(2)(d)

IN THE INCOME TAX APPELLATE TRIBUNAL PANAJI BENCH PANAJI BEFORE SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER &SHRI G D PADMAHSHALI

Perurchettipalayam Paccs, Coimbatore vs. ITO, Ncw-4(2), Coimbatore

In the result, appeals filed by the assessee are allowed

ITA 3223/CHNY/2025[2020-21]Status: DisposedITAT Chennai13 Mar 2026AY 2020-21

Bench: Shri Aby T. Varkey & Shri Inturi Rama Rao

For Appellant: Mr.S. Bhupendran, AdvocateFor Respondent: Mr.N. Madan Kumar, JCIT

Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

considering this specific argument of the Department, the Hon’ble High Court having discussed the definition of 'Cooperative Society' as per Section 2(19) of Tamil Nadu Coop Societies Act, 1983 held, in Para No.9.1 & 10 that the deduction is to be allowed under Section 80P(2)(d), as definition ... deduction under Section 80P(2)(d). In this regard, he referred to the definition to the "Co-operative Societies" as defined under Section 2(19) of the Act and would submit that without taking into consideration of meaning of Co-operative Societies under the wrong impression that the interest received

Perurchettipalayam Paccs, Coimbatore vs. ITO, Ncw-4(2), Coimbatore

In the result, appeals filed by the assessee are allowed

ITA 3222/CHNY/2025[2018-19]Status: DisposedITAT Chennai13 Mar 2026AY 2018-19

Bench: Shri Aby T. Varkey & Shri Inturi Rama Rao

For Appellant: Mr.S. Bhupendran, AdvocateFor Respondent: Mr.N. Madan Kumar, JCIT

Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

Perurchettipalayam Paccs, Coimbatore vs. ITO, Ncw-4(2), Coimbatore

In the result, appeals filed by the assessee are allowed

ITA 3221/CHNY/2025[2017-18]Status: DisposedITAT Chennai13 Mar 2026AY 2017-18

Bench: Shri Aby T. Varkey & Shri Inturi Rama Rao

For Appellant: Mr.S. Bhupendran, AdvocateFor Respondent: Mr.N. Madan Kumar, JCIT

Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

Perurchettipalayam Paccs, Coimbatore vs. ITO, Ncw-4(2), Coimbatore

In the result, appeals filed by the assessee are allowed

ITA 3220/CHNY/2025[2016-17]Status: DisposedITAT Chennai13 Mar 2026AY 2016-17

Bench: Shri Aby T. Varkey & Shri Inturi Rama Rao

For Appellant: Mr.S. Bhupendran, AdvocateFor Respondent: Mr.N. Madan Kumar, JCIT

Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

Nityanand Nagar Vibhag -IV Cooperative Housing Society Limited, Mumbai vs. ITO Ward 24(3)(1), Mumbai

In the result, the appeal filed by the Assessee stands allowed

ITA 494/MUM/2026[2021-22]Status: DisposedITAT Mumbai12 Mar 2026AY 2021-22

Bench: Shri Narender Kumar Choudhryshri Girish Agrawal

For Appellant: Revenue byFor Respondent: Shri Pravin Salunkhe (Sr. DR.)

Section 143(1)Section 2(19)Section 250Section 70Section 80PSection 80P(1)Section 80P(2)(D)Section 80P(2)(d)

investments, and (ii) such investments should be with any other Co- operative Society. Further, the term ,,co-operative society” is defined under section 2(19) of the Act as under: “(19) “co-operative society” means a co-operative society registered under the Co-operative Societies Act, 1912 (2

The Camp Multipurpose Primary Agriculture Cooperative Society Limited, Pernem, Goa vs. Income Tax Officer, Ward 2 (1), Panaji, Goa

In the result, the appeal filed by the assessee is partly allowed

ITA 55/PAN/2026[2016-17]Status: DisposedITAT Panaji11 Mar 2026AY 2016-17

Bench: SHRI PAVAN KUMAR GADALE (Judicial Member)

Section 80P(2)(a)Section 80P(2)(d)

IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH PANAJI BEFORE SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER I T A. Nos.55/PAN/2026

Assistant Commissioner of Income Tax, Aaykar Bhawan, Kolhapur vs. Kolhapur Zilla Sahakari Dudh Utpadak Sangh Limited, Kolhapur

In the result, the appeal of the Revenue is partly allowed for statistical purposes

ITA 300/PUN/2024[2018-19]Status: DisposedITAT Pune11 Mar 2026AY 2018-19

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.300/Pun/2024 Assessment Year : 2018-19 Acit, Kolhapur Vs. Kolhapur Zilla Sahakari Dudh Utpadak Sangh Limited, B-1, Midc, Gokul Shirgaon, Kolhapur – 416234 Maharashtra Pan : Aaaak0230D Appellant Respondent

For Appellant: Shri Sushant PhadnisFor Respondent: Shri Amol Khairnar

Section 143(3)

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES “A”, PUNE BEFORE DR.MANISH BORAD, ACCOUNTANT MEMBER AND SHRI VINAY BHAMORE, JUDICIAL

La Royal Co-Operative Hsg Soc Ltd, Kandivali vs. Assessing Officer, Kautiliya Bhavan

In the result, the appeal filed by the Assessee stands allowed

ITA 443/MUM/2026[2021-22]Status: DisposedITAT Mumbai11 Mar 2026AY 2021-22

Bench: Shri Narender Kumar Choudhryshri Girish Agrawal

For Appellant: Shri Ganshyamlal Kachhara, LdFor Respondent: Shri Pravin Salunkhe (Sr. DR.)

Section 143(1)Section 2(19)Section 250Section 70Section 80PSection 80P(1)Section 80P(2)(D)Section 80P(2)(d)

Shri Brahmanath Credit Souhard Sahakari Sangh Niyamit, Nippani vs. ITO 1 Nippani, Nippani

In the result, the appeal filed by the assessee is partly allowed

ITA 66/PAN/2026[2013-14]Status: DisposedITAT Panaji10 Mar 2026AY 2013-14

Bench: Shri Pavan Kumar Gadalei T A. Nos.66/Pan/2026 (A.Y. 2013-14 ) Shri Brahmanath Credit Vs I.T.O-Ward-1, Souhard Sahakari Sangh Nemchand Building, . Niyamat, 747,Ashoknagar, 185/C, Chikodi Road, Nippani-591237, Nippani, Karnataka. Belagavi-591237, Karnataka. Pan .No. Aaaas1063Q (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.U.G.Ammangi.Ar Revenue By Smt.Rijula Uniyal.Sr.Dr सुनवाई की तारीख/Date Of Hearing 09.03.2026 घोषणा की तारीख/Date Of Pronouncement 10.03.2026 Order Per Pavan Kumar Gadale, Jm: The Appeal Is Filed By The Assesse Against The Order Of Nfac/Cit(A) U/Sec 250 Of The Act. The Assessee Has Raised The Grounds Of Appeal Challenging The Order Of The Cit(A) Sustaining The Denial Of Deduction Of Interest Income From Cooperative Society, Cooperative Banks & Nationalized Banks U/Sec80P(2)(D) Of The Act. 2. The Brief Facts Of The Case Are That, The Assessee Is A Cooperative Credit Society & Is Engaged In Activities Of Providing Credit Facilities To Its Members. The Assessee Has Filed The Return Of Income For The A.Y 2013-14 On 2 Ita. No..66/Pan/2026 Shri Brahmanath Credit Souhard Sahakari Sangh Niyamit. 30.09.2013 Disclosing A Total Income Of Rs.Nil After Claiming Deduction Of Rs.78,06,780/- U/Sec 80P(2)(A)(I) Of The Act. Subsequently The Case Was Selected For Scrutiny Under Cass & Order U/Sec143(3) Of The Act Was Passed Disallowing The Claim U/Sec80P(2)(A)(I) Of The Act Of Rs.78,06,780/- & Disallowance U/Sec40(A)(Ia) Of The Act Of Rs.76,274/- & Assessed The Total Income Of Rs.78,83,054/- Vide Order Dated21.07.2021.Aggrived By The Order, On Appeal To The Cit(A), The Appeal Was Partly Allowed & The Assessee Has Preferred Second Appeal Before The Honble Tribunal & Vide By Order

Section 80PSection 80P(2)(a)Section 80P(2)(d)

IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH PANAJI BEFORE SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER I T A. Nos.66/PAN/2026

Esi Hospital Employees Coop Thrift & Credit Society Ltd., Chennai vs. ITO, Ncw-10(1), Chennai

In the result, the appeal of the assessee is allowed

ITA 3031/CHNY/2025[2022-23]Status: DisposedITAT Chennai09 Mar 2026AY 2022-23

Bench: Inturi Rama Rao & Shri Manu Kumar Giriआयकर अपील सं./Ita No.3031/Chny/2025 िनधा&रण वष& /Assessment Year: 2022-23

For Appellant: Mr. G. Reddi Prakash, C.A +For Respondent: Ms. R. Anitha, Addl. CIT

Section 143(3)Section 144BSection 56Section 80PSection 80P(2)(d)

operative Bank registered under the Co-operative Societies Act. The Income Tax Act, 1961 has also defined 'Co-operative Society' under section 2(19) as follows: '2(19). "Co-operative society" means a co-operative society registered under the Co-operative Societies Act, 1912 (2 of 1912), or under

Girgaon Vijayshree Co Operative Housing Society Limited, Mumbai vs. ITO Ward 19(1)(1), Mumbai

ITA 457/MUM/2026[2021-22]Status: DisposedITAT Mumbai09 Mar 2026AY 2021-22

Bench: Shri Vikram Singh Yadav & Ms. Kavitha Rajagopal

For Appellant: NONEFor Respondent: Shri Aditya Rai, Sr.DR

Section 143(1)Section 80Section 80PSection 80P(1)Section 80P(2)(d)Section 80P(4)

ITA No. 457/Mum/2026 IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI “J-SMC” BENCH: MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT

Shri Mallikarjun Urban Co Operative Credit Society Limited, Belagavi vs. ITO Ward 1 Belgaum, Belgaum

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 65/PAN/2026[2017-18]Status: DisposedITAT Panaji06 Mar 2026AY 2017-18

Bench: SHRI PAVAN KUMAR GADALE (Judicial Member)

Section 80PSection 80P(2)(a)Section 80P(2)(d)

IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH PANAJI BEFORE SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER I T A. No.65/PAN/2026

Avai Pundhari Wcs Ltd., Avalpundurai vs. ITO, Ward-2(1), Erode

In the result, appeal filed by the assessee stands allowed

ITA 3956/CHNY/2025[2016-17]Status: DisposedITAT Chennai06 Mar 2026AY 2016-17

Bench: Shri Inturi Rama Rao & Shri Manu Kumar Giri

For Appellant: Ms. R. Anitha, Addl.CITFor Respondent: 18.02.2026

Section 143(3)Section 2(19)Section 80PSection 80P(2)(d)

interest from the Erode District Central Co-operative Bank, overlooking that the said bank is a co-operative society within the meaning of Section 2(19) of the Act. 5. The order of the CIT(A) is against the principles of natural justice as the detailed submissions and judicial precedents ... operative Bank registered under the Co-operative Societies Act. The Income Tax Act, 1961 has also defined 'Co-operative Society' under section 2(19) as follows: '2(19). "Co-operative society" means a co-operative society registered under the Co-operative Societies Act, 1912 (2 of 1912), or under

Navakarnataka Pss Limited, Hospet vs. Income Tax Officer, Ward-1 & Tps, Hospet

In the result, the appeal filed by the assessee is allowed

ITA 2167/BANG/2025[2016-17]Status: DisposedITAT Bangalore05 Mar 2026AY 2016-17

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2016-17

For Appellant: Smt. Harsha, CAFor Respondent: Shri Subramanian .S, JCIT-DR

Section 142(1)Section 143(2)Section 194ASection 194A(3)(v)Section 2(19)Section 234ASection 250Section 40Section 40aSection 80P

under Karnataka Souharda Sahakari Act, 1997 which are eligible for deduction as they are considered as "co-operative societies" within the meaning of section 2(19) of the Act in the facts and circumstances of the case. 4. The learned Commissioner of Income-tax (Appeals) failed to appreciate that

Grant Road (W) Omkar Co-Operative Housing Soc Limited, Mumbai vs. ITO 19(1)(1), Mumbai

ITA 260/MUM/2026[2021-22]Status: DisposedITAT Mumbai05 Mar 2026AY 2021-22

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhail

For Appellant: Shri Ashok MehtaFor Respondent: Shri Pravin Salunkhe, Sr.DR

Section 143(1)Section 80Section 80PSection 80P(1)Section 80P(2)(d)Section 80P(4)

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI “H-SMC” BENCH: MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER AND SHRI

Grant Road (W) Omkar Co-Operative Housing Soc Limited, Mumbai vs. ITO 19(1)(1), Mumbai

In the result, this appeal of the assessee is allowed

ITA 259/MUM/2026[2020-21]Status: DisposedITAT Mumbai05 Mar 2026AY 2020-21

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhail

For Appellant: Shri Ashok MehtaFor Respondent: Shri Pravin Salunkhe, Sr.DR

Section 143(1)Section 80Section 80PSection 80P(1)Section 80P(2)(d)Section 80P(4)

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI “H-SMC” BENCH: MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER AND SHRI

Marigold Meridian Co-Operative Housing Society Ltd, Mumbai vs. ITO Ward, Mumbai

In the result, the appeal of the assessee is allowed for statistical purpose

ITA 9072/MUM/2025[2018-19]Status: DisposedITAT Mumbai05 Mar 2026AY 2018-19

Bench: Shri Rahul Chaudhary & Shri Bijayananda Pruseth

Section 143(1)Section 143(1)(a)Section 2(19)Section 250Section 80P(2)(a)Section 80P(2)(d)Section 80P(4)

interest income of Rs. 6,69,161/-was not derived from "investments with another Co-operative Society," contrary to the statutory definition under Section 2(19) and judicial interpretation affirming that a Co-operative Bank is also a Co-operative Society. 6. Mischaracterisation of Interest as Surplus Funds

Marigold Meridian Co-Operative Housing Society Ltd, Mumbai vs. ITO Ward-41(2)(3), Mumbai

In the result, the appeal of the assessee is allowed for statistical purpose

ITA 9071/MUM/2025[2021-22]Status: DisposedITAT Mumbai05 Mar 2026AY 2021-22

Bench: Shri Rahul Chaudhary & Shri Bijayananda Pruseth

Section 143(1)Section 143(1)(a)Section 2(19)Section 250Section 80P(2)(a)Section 80P(2)(d)Section 80P(4)

Marigold Meridian Co-Operative Housing Society Ltd, Mumbai vs. ITO Ward-41(2)(3), Mumbai

In the result, the appeal of the assessee is allowed for statistical purpose

ITA 9070/MUM/2025[2020-21]Status: DisposedITAT Mumbai05 Mar 2026AY 2020-21

Bench: Shri Rahul Chaudhary & Shri Bijayananda Pruseth

Section 143(1)Section 143(1)(a)Section 2(19)Section 250Section 80P(2)(a)Section 80P(2)(d)Section 80P(4)